Chief compliance officers are adjusting a new, risk world, where top risks include export controls, sanctions, and immigration enforcement. At the same time, some risks remain — third-party risks, conflict of interest, fair competition, and yes, even anti-bribery.  At the beginning of a new Administration, there is a lag between intentions and actions.  It takes time to move the government enforcement and regulatory machinery and...

When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain.  Sourcing materials and supply chain links present a set of risks.  Conversely, a company’s distribution chain, sales channel, presents another set of challenges.  In each case, legal and compliance have to understand the legal risks presented by...

Trade compliance officers are scrambling — they knew change was afoot but no one expected the speed and wide scope of upheaval in the trade arena.  One day presents potential changes with serious ramifications. In this turbulent era,  legal and compliance have to maintain calm, avoid over-reaction and remain close to their corporate values and principles.  Legal and compliance have to present a steady confidence. ...

The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S. authorities in response to the circumvention of trade restrictions on Russia. Prosecuted in the United States District Court for the Southern District of Florida, the case underscores the severity with which...

Heightened federal scrutiny of unauthorized technology transfers to foreign entities has once again resulted in high-profile criminal convictions, as two senior executives of Quadrant Magnetics, a Kentucky-based manufacturer specializing in rare earth magnetics, have pleaded guilty in federal district court to charges stemming from the unlawful transmission of ITAR-controlled technical data to an affiliate in China. The case, which underscores the heightened scrutiny of corporate...